Richard Chichakli has filed a Pro Se Reply Brief in the appeal of his criminal conviction; It is handwritten, and inscribed upon a legal pad. You may recall that the Bureau of Prisons, which had to deal with the many complaints he aired, about his inability to adequately prepare for trial while incarcerated, initially assigned him to the downtown Federal Detention Center Miami, far from his New York City attorney, as well as the Second Circuit Court of Appeals, which will rule upon his appeal of his conviction and sentence. BOP records now show him back in New York, at Brooklyn MDC.
His counsel had previously filed a Reply Brief, but Chichakli obtained court permission to file his own supplemental reply. He has responded to the US Attorneys' brief with these issues:
(A) The Government knowingly and intentionally offered perjured testimony, and suborned perjury.
(B) The Indictment was varied and altered; the adding of a codefendant is an alteration, if not done by a Grand Jury.
(C) Appellant did not waive extradition.
(D) The Appellant has a cognizable claim for violation of his Constitutional rights, styled as " Ineffective Assistance."
(E) The jury were not informed of the law.
(F) Viktor Bout was referenced as a co-defendant in the trial. Bout is not a defendant, thus the use of his name as a co-defendant seriously prejudiced Appellant.
(G) The use of irrelevant evidence, secret or not, prejudiced Appellant, and is in violation of the Rules of Evidence, by giving the Government unfair advantages, to which the defendant cannot respond.
Chichakli's attorney has requested Oral Argument in this cause. His presumptive release date is June 11, 2017.